Michael Egan III, the man who has sued Bryan Singer and three others for alleged teen sexual abuse in 1997-99, declared under penalty of perjury in a 2003 declaration that one of the men he is now suing for sexual abuse in fact never touched him. A copy of the document, which appears to exonerate defendant David Neuman, is included as an exhibit in a motion to dismiss the case filed Thursday by Neuman’s attorneys in Hawaii federal court.

“I have never had any kind of physical contact with David Neuman other than what is normal and appropriate between non-sexual acquaintances,” says Egan in the declaration. “Up until this last month [December 2003], I have only had incidental social contact with David Neuman, which involved primarily the exchange of polite greetings and small talk. … [Neuman] never acted improperly around me or toward me, on a personal or professional level. … David Neuman has always acted appropriately toward me.”

That declaration is not the only apparent inconsistency that has arisen. Egan also stated in a 2003 deposition that he “never had any trips outside the continental U.S.” with Marc Collins-Rector, Chad Shackley and Brock Pierce, whom he sued in 2000 for alleged sexual abuse. That’s contrary to Egan’s assertions in the suits filed in recent weeks against Singer, Neuman, Gary Goddard and Garth Ancier, which claim that Egan, the three 2000 defendants and the four 2014 defendants all traveled to Hawaii twice in 1999 and that the 2014 defendants sexually abused Egan there.

The Hollywood Reporter has also exclusively obtained additional pages from the 2003 deposition in which Egan says in reference to sexual abuse that no one other than the three 2000 defendants was “partaking in all this stuff.” That seems to contradict the assertions in the 2014 suits.

UPDATE: Egan’s lawyer, Jeff Herman, said “Mike maintains that he was in Hawaii with the defendants and his mother maintains that she spoke to Chad Shackley and authorized him to take Mike to Hawaii on at least two occasions.”

The 2014 defendants have all denied the allegations of sexual abuse, as has Pierce. None of the 2014 defendants were named in Egan’s 2000 lawsuit, despite the fact that the new allegations cover the same time period as the earlier suit. Herman and Egan’s 2000 counsel have both declined to explain why.

Neuman’s motion to dismiss also includes sworn declarations from Neuman and six others asserting that Neuman did not travel to Hawaii in 1999. The motion makes two legal arguments: first, that Neuman was not in Hawaii and the court therefore lacks jurisdiction, and second, that any claim against Neuman should have been brought as part of the 2000 suit.

The motion also “reserves the right to seek appropriate sanctions and reasonable fees,” signaling that Neuman’s counsel may ask the court to fine Egan and/or Herman for bringing an allegedly frivolous lawsuit.

UPDATE: Later in the day Thursday, Neuman’s counsel served Egan’s Hawaii counsel with a motion for sanctions under Federal Rule 11.

Commenting on the deposition excerpts, Goddard’s attorney, Paul Gaspari, said in a statement, “Michael Egan’s … testimony corroborates what we have been saying since this fabricated claim was first made – that Gary Goddard was never in Hawaii with Michael Egan, and never assaulted him in any way. This sworn testimony confirms that Michael Egan was never in Hawaii and he has testified under oath that no one other than those he accused in the 2000 lawsuit, which did not include Gary Goddard, ever assaulted him. The allegations against Gary Goddard are provably false.”